I'm locking this thread so that we can go on about new topics...the report will be out and we will have plenty to mull over then ....
Any argument carried far enough will end up in Semantics--Hartz's law of rhetoric Emerald. Leemer and Southern The route of the Sceptre Express Barry
I just started my blog site...more stuff to come...
http://modeltrainswithmusic.blogspot.ca/
This latest development addresses several questions raised in this thread. It has been discovered that the one running locomotive that was discharging smoke and flames was suffering from a broken piston. Apparently, that cylinder was not firing, and so it was torching and discharging unburned fuel out the exhast stack. The condition developed before the train arrived at Nantes.
Upon arrival, engineer Tom Harding reported the problem to the MM&A dispatcher. Mr. Burkhardt says that this locomotive should not have been left running in this condition.
The TSB has provided a lot of insight into their thinking about train securement and the variable effectiveness of handbrakes in their report on the QNS&L ore train runaway at Doree, Quebec on 12/11/11. It discusses handbrake torque, variation in force applied, lubrication, lever adjustment—all of which can cause variation in handbrake effectiveness. This analysis seems to be the heart of the concern that the TSB has regarding train securement:
http://www.bst-tsb.gc.ca/eng/rapports-reports/rail/2011/r11q0056/r11q0056.pdf
All of the following from the report:
Hand Brakes
The hand brake is a mechanical device allowing the brake shoes to be applied against the wheel treads to prevent the wheels from moving or to retard their motion. The force on the wheels is proportionate to the force exerted by the person applying the hand brake; however, other factors have to be taken into account such as hand-brake-gearing-system lubrication and lever adjustment. According to the Association of American Railroads (AAR) Manual of Standards and Recommended Practices Section S401 rules, to obtain an adequate braking force, the force applied to the wheels of a car by the brake shoes must be equal to about 10% of the car’s gross load (28 000 pounds for LIM cars) when a torque of 125 foot-pounds is applied on the hand brake wheel.
Rule 13 of the Field Manual of the AAR Interchange Rules states that the hand-brake mechanisms and fittings must be inspected, tested and lubricated when a car is on a repair track or in a shop.
The locomotive engineer applied 35 hand brakes and a sample of 15 cars was selected to measure the braking efficiency using a torque wrench. The average torque was approximately 80 foot-pounds, while 2 of the 15 sampled hand brakes had a torque higher than 115 foot-pounds, the lowest value being 45 foot-pounds.
Similar tests conducted as part of the accident that occurred in Edson in 1996 also determined that the torque applied to the hand brakes by an average railway employee could vary between 40 and 120 foot-pounds, with an average of 80 foot-pounds. These tests also revealed that, for a constant torque, for instance 80 foot-pounds, the applied force on the wheels varied between 12 000 pounds and 21 000 pounds.
Concurrent with the tests conducted by the TSB at Sept-Îles, on 31 January 2012, Wabtec Corporation tested the force applied by the brake shoes on a sample of cars. These tests, which use brake shoes with strain gauges, were performed on 3 of the cars on LIM-55 and on another car not involved in the incident. They were conducted at room temperature, in a QNS&L shop and a LIM shop in Sept-Îles. The 4 cars failed the hand-brake tests, measuring just below the minimum 10% force required by the AAR. During these tests, it was noted that excessive force had to be exerted to apply the necessary tension on the hand brake chains of these 4 cars because the hand brake mechanisms lacked lubrication and the lever was out of adjustment.
Wabtec Corporation performed single-car tests on the same sample of 4 cars. Two of these 4 cars passed the test in the empty mode and 3 of the 4 cars passed the test in the loaded mode, but just above the minimum threshold.
Hand-brake Condition
The runaway train travelled almost 15 miles and reached a speed of 63 mph. In such a case, with the brakes applied, it would be expected that the wheels would have overheated and been damaged on the grade. However, examination of the 35 first cars on LIM-55 revealed no abnormal wear on the wheels and brake shoes even though the locomotive engineer indicated that he applied the hand brakes on them before the train ran away.
The force on the wheels is proportional to the force exerted by the person applying the hand brake, but other factors also come into play, such as the lack of lubrication on the hand-brake mechanism and improper adjustment of its components. Each of these conditions, or a combination of these, could have given the operator the false impression that the brakes were sufficiently applied. The torque applied by the locomotive engineer was insufficient to effectively apply the brake shoes against the wheels and prevent their rotation.
Wabtec Corporation had noted that excessive force was needed to apply the necessary tension to the hand-brake chain of the 4 cars tested in Sept-Îles because the hand-brake mechanisms lacked lubrication and the lever was improperly adjusted. Furthermore, when the LIM cars were single-car tested following the incident, the hand-brake mechanisms had to be lubricated and adjusted on all the cars.
Hand-brake inspections required in accordance with Rule 13 of the Field Manual of the AAR Interchange Rules apply only when a car is on a repair track or in a shop. Therefore, these inspections would normally be performed at the same time as a single-car test. However, because single-car tests were not conducted on the vast majority of cars before they were put in service, the hand-brake defects were not identified.
Train Securement between Bybee and Tika
When a train stops in the slope between Bybee and Tika following emergency braking, it must be secured in accordance with CROR Rule 112 and related special instructions. Rule 112 special instructions specify the minimum number of hand brakes needed in general operating conditions, but do not give the number when specific conditions apply. It is up to the locomotive engineer to determine the number of hand brakes required. In this incident, for LIM-55, the locomotive engineer, taking into consideration conditions such as track grade and train specifications, determined that 35 hand brakes were sufficient. However, given the torque applied and the condition of the brakes, that number proved insufficient to prevent the train from running away.
Employees rely on their personal experience gained in situations where cars have either not moved or ran away to determine the sufficient number of hand brakes to be applied. Standard operating practices do not take into account that hand brakes can be applied in varying degrees, depending on the wheel torque. Yet, the amount of torque that employees can physically apply to the wheel varies from one to the other. Torque variability is affected by the design, condition and maintenance of hand brakes as well as differences in physical capabilities among locomotive engineers.
The car weight and type, track gradient where the cars are left and actual and possible wind speed and direction must also be considered when deciding the sufficient number of hand brakes needed to secure a train. Determining what constitutes a sufficient number of hand brakes requires more information than locomotive engineers may have available to them and a better comprehension of the relevant variables and their relationship. This means that each locomotive engineer is left with the decision to determine how many brakes should be applied and to what degree.
Locomotive engineers who apply hand brakes do not receive any definitive feedback to confirm that sufficient brake shoe force was attained. Furthermore, because it is impossible to verify hand-brake effectiveness by pulling or pushing cars on high grades, locomotive engineers cannot accurately know that management’s expectations have been met every time cars are secured in accordance with CROR Rule 112. Other railway companies in Canada have enhanced CROR Rule 112, on high-grade sections of track, by putting into place procedures detailing the application and the number of hand brakes required. Without specific instructions that take into consideration local conditions, there is a risk of underestimating the number of hand brakes required to secure a train on a steep grade such as between Bybee and Tika and consequently other trains could run away.
I agree that some of the micro-management is silly, but that can come from railroad management as well (i.e., CP and others not allowing trainmen enter/exit moving equipment because of the fear of lawsuits). But some form of regulation (which means confirmation) is necessary to keep railroad management from going too far in the other direction, cutting costs to the bone and "hoping for the best," which is fairly clearly the case in the MM&A accident. BTW, MM&A is trying to return to two-person minimum crews in the US but needs extra cash to so so. Their former one-person per 70 petro car train setup is a clear case of a company enjoying the benefits of a risky move while not paying most of the costs. Canada, through the TSB regulators, has wisely disallowed it, something the railroad did not do on its own until the damage was done.
jeffhergert I must say I'm beginning to hold the Canadian TSB in the same regards as our NTSB. Not very highly. I think they do a good job in finding out what went wrong, but their recommendations are sometimes (IMO) suspect. I feel that often their recommendations are for absolute risk free, perfect world outcomes that often aren't practical for real world situations. (It started years ago after a train/school bus accident where they were critical of objects on the train that made the impact worse on the bus and would like to see them removed. Things like the coupler.) The FRA's EO order now requires on key trains that the lead engine have the cab doors locked, or it that's not possible, to have the reverser removed when left unattended outside of terminals. Nothing wrong with that, but what about the trailing engine(s)? All right to leave them unlocked and accessible to anyone. Any one else see a problem there?
I must say I'm beginning to hold the Canadian TSB in the same regards as our NTSB. Not very highly. I think they do a good job in finding out what went wrong, but their recommendations are sometimes (IMO) suspect. I feel that often their recommendations are for absolute risk free, perfect world outcomes that often aren't practical for real world situations. (It started years ago after a train/school bus accident where they were critical of objects on the train that made the impact worse on the bus and would like to see them removed. Things like the coupler.) The FRA's EO order now requires on key trains that the lead engine have the cab doors locked, or it that's not possible, to have the reverser removed when left unattended outside of terminals. Nothing wrong with that, but what about the trailing engine(s)? All right to leave them unlocked and accessible to anyone. Any one else see a problem there?
Jeff,
Very insightful point you've made.
There is a difference in skill sets, knowledge and mindset needed to determine the root cause of an accident as opposed to the skill sets knowledge and mind sets needed create the policies necessary to prevent future accidents, especially when there are several contributing factors to the accident. Being government agencies, they are at best less sensitive to the economic fallout of implementing the suggested changes (e.g. PTC) - this is important as implementing a policy with a high cost per life saved will divert resources from implementing policies that save more lives for a given cost.
- Erik
It is easy to dismiss a government regulatory as not knowledgeable because it is composed of uniformed bureaucrats. However, it is also easy to check and see the the Canadian TSB has and seeks professionals from air, water and rail backgrounds for its investigative staff:
(from the TSB website): "Our investigators include people with backgrounds in the transportation industry and regulatory sectors as well as the military. If you are, just to name a few, an air traffic controller, aircraft pilot, helicopter pilot, aircraft maintenance engineer, master mariner, naval architect, marine chief engineer, locomotive engineer, rail equipment and infrastructure specialist or have engineering certification in pipeline, you may be interested in a change of career that allows you to channel your experience into a rewarding career as a TSB investigator.
Employees who work as investigators usually belong to these occupational groups:"
C&NW, CA&E, MILW, CGW and IC fan
Thanks for your comments. I am not sure what you are referring to regarding a means to get a handbrake really tight. I know of one, but it is dangerous and prohibited. I agree that the TSB’s reasoning about setting a prescribed number of handbrakes without a test is unreliable. But it sounds as though they think they can get around that problem by requiring a number of handbrakes that is far in excess of what would be actually necessary. So, while the securement would still be unreliable, they could reduce the probability of it failing to near zero.
It raises the question of how the TSB will find how many handbrakes are actually necessary. They could make calculations based on pure physics. Or they could conduct their own practical tests at each location with a variety of cars and tonnage.
But they have not actually announced their ideas, so we are left with only many fragments of their reasoning to anticipate where they are headed. In one article, it was presented as though crews would be given the option of either applying the high number of handbrakes required for a fixed number securement rule; or doing a push-pull test and using the number of handbrakes that the test determined. If that is what they intend, it seems really bizarre. It seems like a version of having your cake and eating it too—at the expense of not solving the problem.
I think I'd call that 4 Tequila thinking myself.
I do think the idea of hiring folk who know something of what they speak is a good idea...if the management of TSB are really connected to real world thinking.. but...we all know how that goes Will they get heard is something else...
jeffhergert I must say I'm beginning to hold the Canadian TSB in the same regards as our NTSB. Not very highly. I think they do a good job in finding out what went wrong, but their recommendations are sometimes (IMO) suspect. I feel that often their recommendations are for absolute risk free, perfect world outcomes that often aren't practical for real world situations. (It started years ago after a train/school bus accident where they were critical of objects on the train that made the impact worse on the bus and would like to see them removed. Things like the coupler.) The FRA's EO order now requires on key trains that the lead engine have the cab doors locked, or it that's not possible, to have the reverser removed when left unattended outside of terminals. Nothing wrong with that, but what about the trailing engine(s)? All right to leave them unlocked and accessible to anyone. Any one else see a problem there? Jeff
Jeff
Lock the lead unit and leave the rest of them unsecured? What kind of three-martini-lunch type of thinking is that? Sheesh!
Jeff, you raised a lot of very good points to ponder as well as providing a great deal of valuable information. To an outsider, it looks like the FRA EO order is an incomplete attempt at a solution that leaves you wondering, "what am I supposed to do about that?"
Bucyrus Norm48327 BucyrusBut the flaw in the prescription of a specific number of handbrakes is that there is no way to control how tightly somebody sets them, or how effective each handbrake will be according to its mechanical condition. I've never set a handbrake, but I would think an average person could tighten one securely enough to hold a car. I don't see any 800lb gorillas working on the railroad. Norm, When you set a handbrake, it amounts to turning a very “low gear” winch that gradually pulls the mechanical rigging that forces the brake shoes against the wheels. All of the rigging yields collectively like a spring under the pull of the brake wheel winch. It is not hard to set a handbrake tight enough to do the job. The issue is that there is no indication that tells the trainman when the handbrake is set to its maximum. When the company tells you to set a handbrake, they do not tell you how tight to set it. So when a person sets a handbrake, it may not be set as much as it could be to be fully effective. Or it is possible that the body builders could set a handbrake so tightly that the chain breaks. The issue of setting handbrakes for train securement is that it requires setting many of them. Their effect is cumulative. So if a person setting the handbrakes is inclined to set them in a childlike manner, thirty of them might be entirely insufficient to secure the train. If a person sets them robustly, ten of them might be sufficient. That is just the issue of how strongly the setter sets them. The other half of the equation is that handbrake mechanisms get differing amounts of cleaning and lubrication. So winding the wheel to a certain torque is only half the story. Two brakes wound to the same torque could yield vastly different amounts of braking due to the difference in maintenance, cleaning, and lubrication.
Norm48327 BucyrusBut the flaw in the prescription of a specific number of handbrakes is that there is no way to control how tightly somebody sets them, or how effective each handbrake will be according to its mechanical condition. I've never set a handbrake, but I would think an average person could tighten one securely enough to hold a car. I don't see any 800lb gorillas working on the railroad.
BucyrusBut the flaw in the prescription of a specific number of handbrakes is that there is no way to control how tightly somebody sets them, or how effective each handbrake will be according to its mechanical condition.
I've never set a handbrake, but I would think an average person could tighten one securely enough to hold a car. I don't see any 800lb gorillas working on the railroad.
Norm,
When you set a handbrake, it amounts to turning a very “low gear” winch that gradually pulls the mechanical rigging that forces the brake shoes against the wheels. All of the rigging yields collectively like a spring under the pull of the brake wheel winch.
It is not hard to set a handbrake tight enough to do the job. The issue is that there is no indication that tells the trainman when the handbrake is set to its maximum. When the company tells you to set a handbrake, they do not tell you how tight to set it. So when a person sets a handbrake, it may not be set as much as it could be to be fully effective. Or it is possible that the body builders could set a handbrake so tightly that the chain breaks.
The issue of setting handbrakes for train securement is that it requires setting many of them. Their effect is cumulative. So if a person setting the handbrakes is inclined to set them in a childlike manner, thirty of them might be entirely insufficient to secure the train. If a person sets them robustly, ten of them might be sufficient.
That is just the issue of how strongly the setter sets them. The other half of the equation is that handbrake mechanisms get differing amounts of cleaning and lubrication. So winding the wheel to a certain torque is only half the story. Two brakes wound to the same torque could yield vastly different amounts of braking due to the difference in maintenance, cleaning, and lubrication.
Most tighten the wheel until they can't turn it any more. Some may be able to get an extra "click" or two on the wheel over others. That cleaning and lubrication part to me seems a bit out there. Unless there's a mechanical problem, such as binding in the chain or rigging, the brake will be tight. If you really want to put a hand brake on really tight, there's a trick to do that if the car has air on it. I'll assume you know it, so I won't elaborate. (If anyone who doesn't know asks, I'll let you answer it too.)
Using the Canadian TSB's reasoning that the verification test is unreliable, you can't set out or leave unattended equipment any where at any time. Even if you applied the hand brake on every car on a blind siding, whether it be one or one hundred, since the verification test is unreliable you can't say you have applied a sufficient number of hand brakes.
Yes, I'm aware and have mentioned there is a chart for times when it is impractical to release the air. It's more for times when you are leaving a small number of cars on the end of a large cut. Such as leaving 6 or 7 empties off of a 100 car cut of loads. You could apply all the hand brakes on the cars which might be overkill for the 6 or 7 you're leaving, release the air and still have the rest of the cut move. It's not for times when you are leaving an entire train and engine. In that case they want to see the verification of the air brakes being released. I have seen some changes my company has recently made after the FRA's EO came out that suggest to me that eventually the chart may become the new minimum number, but still require a verification test in most cases.
Bucyrus But the flaw in the prescription of a specific number of handbrakes is that there is no way to control how tightly somebody sets them, or how effective each handbrake will be according to its mechanical condition.
But the flaw in the prescription of a specific number of handbrakes is that there is no way to control how tightly somebody sets them, or how effective each handbrake will be according to its mechanical condition.
Norm
tree68 BucyrusHowever, if the rule called for a specific number, there would be solid evidence of the rule compliance if cars ran away after securement. So what happens if the proper number of brakes are set, according to the rule, and the train runs away?
BucyrusHowever, if the rule called for a specific number, there would be solid evidence of the rule compliance if cars ran away after securement.
So what happens if the proper number of brakes are set, according to the rule, and the train runs away?
I don’t know the answer to that. The presumption is that the number of handbrakes specified in the rule will do the job. If it does not, I don’t see how the crew can be blamed if they set the number called for in the rule. But the flaw in the prescription of a specific number of handbrakes is that there is no way to control how tightly somebody sets them, or how effective each handbrake will be according to its mechanical condition.
I don’t see a practical way to get around that flaw. Apparently the only way the TSB sees to get around the flaw is to call for a number of handbrakes that greatly exceeds what is necessary. But then that adds excess cost to the business.
And it is still no guarantee of securement even though there is the assumption of a huge safety factor. I would say that this is what happens when bureaucracies roll their sleeves up and go to work on a problem.
tree68So what happens if the proper number of brakes are set, according to the rule, and the train runs away?
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Larry Resident Microferroequinologist (at least at my house) Everyone goes home; Safety begins with you My Opinion. Standard Disclaimers Apply. No Expiration Date Come ride the rails with me! There's one thing about humility - the moment you think you've got it, you've lost it...
It is a bit strange, although understandable, that the TSB sees the lack of an absolute number of handbrakes to apply as a defect. It seems that they want to give orders to employees that are absolutely specific, and the only way to accomplish that is with a specific number.
The push-pull test does yield an absolute number, and it is a number proven to work by the very test that provides it. Yet the TSB seems not to trust that approach of letting the employees find the number. They seem to feel the testing method is a little too organic. In a way, it empowers the employees to make their own rule by performing a practical experiment.
The number dictated by the test is also a number that nobody can dispute after the fact. If the train runs a way, obviously the number was too low. Yet, if the employee says the push-pull test showed the number to be sufficient, it is their word against the company’s word.
However, if the rule called for a specific number, there would be solid evidence of the rule compliance if cars ran away after securement. The evidence would simply be finding and counting handbrakes set on the runaway cars. If the cars happen to derail, some of the evidence might be obliterated, but still, there is a fair chance of evidence.
Another point to consider is that rule compliance testing in the field could check handbrake securement after it had been completed by simply counting the number of set handbrakes. This compliance testing would not be possible if the number of handbrakes had been determined by a push-pull test. Therefore if the rule called for a specific number of handbrakes, thus making compliance testing possible; the threat of discipline would encourage more compliance.
BucyrusBut there is a problem with relying only on a requirement for setting a specific number of handbrakes. It is a two-part problem. One part is that the condition of handbrakes varies, so two brakes applied to the same tightness might not provide the same holding power. The second part of the problem is that there is no way to control how tightly a person applies the handbrakes.
I don't always agree with Bucyrus, but I will give credit where it is due, and he hit the nail on the head here.
It seems TSB (or whomever) is trying to find an absolute number. when it is possible that such a thing does not exist. I am lucky(?) enough to work in a yard that sits on a pretty good grade. And we switch cars without air most of the time. So, yeah. I deal with a lot of handbrakes. We have minimums for tracks, but also a requirement to test the handbrakes before cutting away. Almost like the push-pull test, but it more concerned with slack. There's times where the minimum is NOT enough to hold the cut of cars (maybe due to brake conditions, or the cars having truck-mounted brakes) and there's other times it is simply overkill.
You may need x number of brakes, but you're only putting x+1 cars on the track. Yet, you still put on x brakes, as that is the rule, and following the rules is part of the job. I know lawmakers and lawyers don't like answers that sound like "it depends", but hey, it is what it is.
It's been fun. But it isn't much fun anymore. Signing off for now.
The opinions expressed here represent my own and not those of my employer, any other railroad, company, or person.t fun any
narig01More news. Possibility of arrests. http://trn.trains.com/Railroad%2520News/News%2520Wire/2013/09/Arrests%2520expected%2520in%2520Lac%2520M%25C3%25A9gantic%2520derailment.aspx And from the Toronto Globe & Mail https://www.google.com/url?q=http://www.theglobeandmail.com/news/national/arrests-in-connection-to-lac-megantic-rail-disaster-looming/article14272125/&sa=U&ei=2D4yUu2SD4rV2QXI0oDYAg&ved=0CCQQqQIwAA&sig2=nyHFM9MmzIa2FvA7juyvmw&usg=AFQjCNGPgg3AwekyPha2d5qYkHo881viWg Also if my links don't post could someone fix. Thx It will be interesting to see who would be charged Rgds IGN
Thx for posting!!
OK guys, today alone I removed ten off topic posts from this thread and despite having been advised several times to keep the thread on topic. It's the same people every time (you know who you are) that are making the off topic postings. Now I'm telling you again, keep the thread on topic as per the subject title.
All through the media discussion of the rules, it is indicated that the authorities rely on the push-pull test as the ultimate indicator of proper securement, but at the same time, the authorities lament that a specific number of handbrakes is not stated in rules. They say this leaves trainmen guessing. Even though the push-pull test is supposed to eliminate the guesswork, its result can vary according the amount of force applied. There might be a tendency to use too little force because too much force will break a knuckle or jackknife the train. Using too little force might leave the test passing with too little safety margin.
The TSB has come right out and said that it is impossible to confirm the securement with the push-pull test. So they don’t like relying on the test. Instead they want to specify a specific number of handbrakes to apply. They say that takes the guesswork out of the operation. They have complained that CROR Rule 112 does not require a specific number of handbrakes.
But there is a problem with relying only on a requirement for setting a specific number of handbrakes. It is a two-part problem. One part is that the condition of handbrakes varies, so two brakes applied to the same tightness might not provide the same holding power. The second part of the problem is that there is no way to control how tightly a person applies the handbrakes.
Because of these variables in handbrake performance and operation, the actual effect of a given number of handbrakes cannot be determined. The only way to overcome this problem with calling for a specific number of handbrakes is to set that number much higher than it needs to be to actually do the job. The high number will provide a massive safety factor that is likely to overcome the performance variables. But the problem with that is that the massive safety factor requires a lot of extra time and money for the labor to set the excess brakes.
So, according to this latest information, the remedy to the excess labor is to allow an alternative to it. The alternative is that a person can disregard the high number specified in the rules if he does a push-pull test that indicates a lower number will get the job done. But isn’t this right back to where we started? Who is going to set an excess of handbrakes if they don’t have to? If you don’t have to set the high number specified in the rule, why specify it?
Here you go IGN:
http://trn.trains.com/en/Railroad%20News/News%20Wire/2013/09/Crude%20oil%20mislabeled%20in%20Lac%20M%C3%A9gantic%20incident.aspx
http://www.theglobeandmail.com/news/national/crude-that-exploded-in-lac-megantic-was-mislabelled-regulator-says/article14239877/
Eric, are you referring to the amount of heat available in each molecule? The more volatile liquids have less heat available per molecule because they have fewer carbon and hydrogen atoms per molecule. The higher hydrocarbons, which have more heat content, are less volatile. The more volatile liquids provide more vapor for ignition quickly; remember that it is not the liquid that burns, but the vapor that burns.
Johnny
The MM&A uses the special instructions for handbrakes that are used by Canadian Pacific Ry. Since the runaway, CP has made some two-dozen changes to the handbrake section of the General Operating Instructions. The company removed a chart that gave minimum hand brake requirements for trains based on the number of cars. That chart had said a minimum of nine hand brakes were needed on a train with 72 cars.
According to the article linked below, the CP has replaced the chart with new rules that say hand brakes must now be applied on at least 25 percent of the cars for trains parked on a slope of 1.2 percent (which is the grade of the tracks outside of Lac-Megantic); unless the brakes have been properly tested.
I don’t understand what they mean by saying “unless the brakes have been properly tested.” I assume that “tested” refers to the push-pull test required by CROR Rule 112. Why would the brakes not have been properly tested?
So, does that mean Rule 112 is now only an option, and if you choose to exercise it; and if it's push-pull test shows that less than 25% is satisfactory; then you are free to ignore the requirement of setting 25% and are permitted to set only the number of handbrakes required by the push-pull test?
And by the same token, are you free to not to exercise Rule 112 with its push-pull test if you set 25% of the handbrakes?
If that is the proper interpretation of what they have changed, it seems like a big change in the rule logic. It would amount to an option of using either of two different methods, and the two methods will not necessarily yield the same result.
http://www.reuters.com/article/2013/07/19/us-train-probe-idUSBRE96I0OO20130719
edblysardWrong…
Ed,
I understand what you are saying about companies being prohibited from making their own rules less restrictive than the federal rules. Nothing has been said to the contrary, so I don’t understand why you began your reply with “wrong.”
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